THE SENIOR ALLIANCE ANNUAL VENDOR MEETING AND TRAINING · THE SENIOR ALLIANCE ANNUAL VENDOR MEETING...
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THE SENIOR ALLIANCE ANNUAL VENDOR MEETING AND TRAINING NOVEMBER 5, 2019
Transcript of THE SENIOR ALLIANCE ANNUAL VENDOR MEETING AND TRAINING · THE SENIOR ALLIANCE ANNUAL VENDOR MEETING...
THE SENIOR ALLIANCE
ANNUAL VENDOR
MEETING AND TRAINING
NOVEMBER 5, 2019
Ground Rules
Please turn cell phones off or set to “vibrate.” Be courteous to those around you and refrain from side
conversations.
Hold all questions until the end of each section of the presentation.
Please state your name and the name of the vendor agency you represent before asking a question.
At the end of this presentation is an attached document that must be signed and returned to TSA. Please be sure to do this before you leave.
This presentation will be available on TSA’s website: http://www.aaa1c.org/doing-business-with-us/purchase-of-service-pos-provider/
Agenda
1. Introduction – TSA Staff
2. Presentation by Jeff Schroder – Plunkett Cooney
3. Updated Standards
4. Service Standard Verification
5. Timesheet Accuracy/Fraud Implications
6. Common Caregiver Issues
7. Criminal History Screenings and Exclusion Checks
8. Invoicing Information
9. CCD Training
10. Questions
11. Acknowledgement Signature Page
INTRODUCTION/CONTACT INFORMATION
Tamera Kiger Chief Executive Officer
Kishori Gandhi Chief Financial Officer/Deputy Director
Kelly Faber CCD Chief Clinical Officer
Lydia Gold Compliance Officer
Elizabeth Browning Director of Programs and Special Projects
Gail Wejrowski CCD Waiver Clinical Manager
Andrew Dabrowski CCD Program Manager
Megan Silverman CCD Quality Manager
Melissa Gaynier CCD Program Manager
Tara Price CCD Training Manager
Jeffery Hawkins Accounting Manager 734-727-
2018
Katherine Stoyanovich Accounting Manager 734-727-
2077
Beth Wright Contract Specialist 734-727-
2085
Sue Colson Accounting
Specialist
734-727-
2068
Katie Teachout Accounting
Specialist
734-736-
6960
Deborah Forest Accounting
Specialist
734-727-
2050
Adiell Childress Accounting
Specialist
734-736-
6060
Renee Farrugia CCD Support
Specialist
734-727-
2051
Johnna Warner Transportation
Coordinator
734-727-
2059
Robert Bizon Vendor View
Registration
INTRODUCTION/CONTACT INFORMATION
Presentation by
Jeff Schroder Senior Attorney at
Plunkett Cooney
Updated Standards
Aging and Adult Services Agency programs and MI
Choice Waiver have updated their standards.
TSA and Vendors must comply.
Noncompliance may result in action up to contract
termination.
Current version includes some changes that affect
Vendors.
Updated Operational Guidelines list these new
standards.
Background Check Requirements
Additional Background Checks are required.
ICHAT checks are still required. Print the results for your
records.
Federal Sex Offender Registry
https://www.nsopw.gov/
Go to the website
Enter the person’s name
Press the “enter” key
Print the results for your records.
Background Check Requirements
Michigan Sex Offender Registry
https://www.michigan.gov/msp/0,4643,7-123-1878_24961---,00.html
Go to the website
Click on “Search the Michigan Sex Offender Registry”
Click on “Click Here to Search for Offenders in your Area
Select the “Name” tab
Enter the person’s name and click on “search”
Print the results for your records.
Central Registry Clearance for anyone working with children or vulnerable adults
Central Registry Clearance
Paper form process
Applicant fills out and signs the form (DHS-1929)
Mail or fax the form to the local MDHHS office
Clear results will be mailed to employer. Results showing a central registry listing will be mailed to the individual.
Results are mailed within 10 days.
Keep all documentation for your records
TSA will email copy of the form.
Frequency of Background Checks
All background checks must be completed at hire
(ICHAT, Central Registry, National Sex Offender
Registry, and Michigan Sex Offender registry)
The following must be completed every three
years at minimum and preferably annually:
ICHAT
National Sex Offender Registry
Michigan Sex Offender Registry
Additional Requirements
Vendor must decide whether to prohibit individual from working with participants or accessing information based on background check results
Employees, volunteers, contractors and contractor employees must disclose in writing within 10 days any criminal convictions, pending felony charges, or placement on the central registry
Vendor must not have committed an act of so serious or compelling nature that it affects the
current responsibilities
General New Provisions
Must comply with Anti-Lobbying Act
Must have whistleblowing protections in place
Publicity and Publication Rights
Must have TSA and MDHHS approval for media releases related
to the contract and must acknowledge TSA and MDHHS in all
publications, papers and presentations
Must obtain prior written authorization from TSA and MDHHS for
materials acknowledging TSA or MDHHS
New Insurance Requirements
Additional insurances are required
Cyber liability: $500,000 minimum
Sexual Abuse and Molestation Liability: $500,000 minimum (may be included in General Liability as Abuse Coverage – check with insurance provider)
Employer’s liability: $500,000 minimum (may be included in Workers’ Compensation – check with insurance provider)
All vendors need to submit evidence of having both types of insurance no later than 11/15/19.
All former insurance requirements still stand (see next slide).
Insurance
The following insurance is required to be renewed and kept at the required limits throughout the Agreement period:
General and Professional Liability: $1,000,000 limits minimum, TSA listed as additional insured
Auto Liability: $1,000,000 limits minimum, TSA listed as additional insured
Transportation vendors with company vehicles must include “scheduled autos”
Worker’s Compensation: $500,000 limits minimum
Third Party Crime/Dishonesty Bond: $50,000 minimum per occurrence
TSA must be listed as certificate holder.
Vendor is required to have their insurance provider send updated certificates before the expiration date.
If updated insurance is not received by the expiration date, corrective action may be taken, including contract termination.
Year End Turn
Vendors must print out authorizations for MI Choice
and CM/CCS participants that ended on 9/30/19
and begin on 10/1/19.
Individual notifications will not be sent out for each
participant needing a new authorization starting
10/1.
This is per the direction of Center for Information
Management (CIM).
If you do not see a current authorization for each
participant under “Service Reports,” contact the SC.
Annual Service Standard Verification (ASV)
TSA is requiring that the following documentation be submitted on an annual basis in order to confirm compliance with MDHHS standards.
Updated copies of these documents may be requested at any time throughout the year for audit purposes.
When licenses expire, renewed copies need to be sent to TSA.
Vendors will receive tools based on contracted services and a Compliance Attestation Tool via email in the near future.
Home Care Provider ASV
Copies of updated RN license for supervision
Current background check
Policies on:
All caregivers are at least 18 years old
Caregivers can effectively communicate written and orally
Higher-level non-invasive tasks must only be performed by workers trained/supervised by an RN.
Relevant experience in housekeeping, good health practices, observation, reporting, identifying abuse/neglect, food prep
First aid, universal precautions, and blood-born pathogens training
Background checks
Additional Home Care Standards
If caregivers are transporting participants, they must be properly licensed and insured.
Family caregivers cannot be the spouse of the participant.
Family members who provide home care services must meet the same standards as caregivers who are unrelated to the participant.
If the participant is not able to administer their own medications, the medication must be administered by properly trained staff/under the supervision of trained staff.
In licensed residential settings (AFC/HFA), the owner/managers of the facility qualify to supervise staff.
Fiscal Intermediary ASV
Evidence of being bonded/insured.
Readiness Review documentation.
Demonstrated ability to manage budgets
Able to manage activities related to employment
taxation, worker’s comp, state/local/federal
regulations
Home Delivered Meals (HDM) ASV
License - Health Code Standards (PA 368 of 1978)
Capacity to provide 3 meals per day at least 5
days per week that meet the Dietary Reference
Intake (DRI) and Recommended Dietary Allowances
(RDA) standards.
Policies on continuing services in the case of an
emergency.
Product liability insurance.
Food shall be delivered at safe temperatures.
Additional HDM Standards
Unless otherwise preferred by a participant,
vendors must not provide more than a two week
supply of frozen meals per delivery.
Use person-centered planning principles when meal
planning for participants.
Be able to provide a nutrient analysis for a meal
upon request.
Adaptive Medical Equipment (DME)
ASV
Be enrolled in Medicare and Medicaid as a
Durable Medical Equipment provider.
Updated copy of DME license.
Adult Day Care (ADC) ASV
Program Director must have a minimum of a Bachelor’s Degree in a health or human services field, or be a qualified health professional.
Staff at a ratio of no less than one staff member for every 10 participants.
Provide health support services under the supervision of a RN.
Staff must be trained in basic first-aid.
If participants are transported, drivers must be licensed, vehicles must be licensed and registered with the Secretary of State, and drivers must comply with P.A. 1 of 1985 regarding seat belt usage.
First-aid materials must be available on site.
At least one staff person must be trained in CPR.
ADC ASV Continued
Emergency procedures must be posted in all rooms.
Fire drills must be completed and documented every 6 months.
ADC shall have the following:
One straight back or sturdy chair per participant and staff person
Lounge chairs or day beds for naps/rest periods
Storage space for participant’s personal belongings
Tables for ambulatory/non-ambulatory participants
Accessible telephone
Special equipment to assist persons with disabilities
ADC shall be compliant with:
Barrier-free design/local building codes
Fire safety standards
Applicable Michigan/local public health codes
Additional ADC Standards
1 hot meal must be served per 8 hour day.
Must have written consent from the
participant/representative to assist in taking
medications, along with medication administration
policies and training.
Chore Services ASV
Pest Control vendors must be properly licensed.
Home Modifications ASV
Home mod providers must be properly licensed
(Builder’s license) and meet the following:
MCL 339.601(1)
MCL 339.601.2401
MCL 339.601.2403(3)
Transportation ASV
All drivers must have valid Michigan Chauffeur driver’s
licenses.
Secretary of State must appropriately license and inspect
all vehicles.
Vehicles must be all covered with liability insurance.
Drivers must be physically capable and willing to assist
persons requiring help getting in and out of vehicles.
Drivers must be trained to cope with medical emergencies
and properly securing wheelchairs in vans.
All drivers must comply with P.A. 1 of 1985 regarding
seat belt usage.
Personal Emergency Response
System (PERS) ASV
Federal Communication Commission must approve equipment used.
Equipment must meet UL safety standards 1637 for Home Health Signaling Equipment.
Response centers must be staffed 24 hours a day, 365 days a year.
Must provide accommodations for persons with limited English proficiency.
Response center must be able to respond to all incoming emergency signals and accept multiple signals simultaneously.
Additional PERS Standards
Verify participant information on a semi-annual
basis to ensure current and continued participation.
Conduct at least monthly testing of each PERS unit.
Provide ongoing assistance in the use of the devices
to participants and caregivers.
Keep records of service delivery, emergency
responders for each participant, and a log of all
participant and responder contacts.
Preventative/Private Duty Nursing
ASV
All nurses must be properly licensed under the
standards Nursing MCL 333.17201-17242.
All nurses must maintain a current Michigan nursing
license.
Vendor must send in RN/LPN licenses for all new
hires.
Nursing Services/PDN may include medication
administration.
LPNs must be supervised by RNs.
In-Home Respite ASV
Must also meet requirements of service code H2015.
Must have written procedures that govern assistance given to participants in self-medication, which include review of medications, verification of dosages, instructions for entering medication information into participant files, and a statement of the responsibilities of the participant/family.
Procedures must be reviewed by a physician/pharmacist/RN.
Supervise staff providing respite with a professionally qualified supervisor.
Out-of-Home Respite ASV
Provider must be a licensed Adult Foster Care (AFC
– Act 218 of 1979) or Homes for the Aged (HFA –
MCL 333.21311).
Must employ a professionally qualified program
director.
Must demonstrate a working relationship with a
hospital or other health care facility.
Must have emergency notification plans in place for
each participant.
Sample Service Verification Form
Sample of service verification form you will receive.
1 form per contracted service.
Vendor must attest on the form that all applicable service standards are being met.
Supporting documentation must be sent with form.
Supervisory Visits
Supervisory Visits – RNs are required to perform
supervisory visits for H2015 and T1019 services.
This standard is from the MI Choice Waiver
Operating Standards and MI Health Link Operating
Standards.
This includes tasks like bathing, incontinence,
medication reminders, and dementia care.
Vendors must have evidence of 2 supervisory visits
performed by an RN per year.
Nursing Notes
If you provide nursing services, you are required to send monthly nursing notes to TSA through vendor view. These must be sent by the 5th of the month.
Nursing notes must include:
Summary of participant’s current health conditions
Changes in health from previous assessment
Tasks being performed are per physician’s orders (Yes/No)
Tasks performed are meeting participant’s medical needs (Yes/No)
Additional comments
This is a major compliance issue. TSA may take corrective action up to and including contract termination for those vendors who continuously do not submit nursing notes.
OIG Reporting
Office of Inspector General (OIG) is requiring that certain information be submitted in quarterly reports for MI Choice Waiver participants.
TSA will be reporting to OIG any time that any money is deducted from a POS Vendor payment.
This includes:
Assessment findings
Billing when services were not provided for any reason, including missed visits, hospitalizations, nursing home admissions, participant not home, etc.
Paper bill edits
Data mining activities
OIG Reporting
The state will now be aware of any time Vendors
bill when services were not provided, including
deductions in payments from discrepancies at audits
and billing when participants are in the hospital.
This shows the importance of ensuring that bills
are only submitted when services were provided.
Vendors should also stress the importance of
having proper backup documentation (timesheets)
to support all units billed.
OIG Reporting
TSA is also required to send reports to OIG
throughout the year regarding the following:
Vendors/caregivers suspected of committing fraud
Vendors/individuals who are found to have active
exclusions
Any time TSA takes adverse action against a Vendor
(termination of contract)
Any time TSA requests that the vendor send support
documentation before a bill is approved
Timesheet Accuracy
All caregivers should be trained on how to properly fill out timesheets.
Importance of accurate timesheets should be stressed.
Errors on timesheets/missing components can be considered fraud.
Participants should be signing timesheets that accurately describe the services that were provided.
Units should not be billed in vendor billing if there is not an accurate timesheet signed by a participant to support the units.
Timesheets
The following areas should be emphasized:
Participant Name/Employee Name
Date & Time In/Time Out (AM &PM)
Unit Breakdown
Tasks Completed
Participant Signature
Caregiver Signature
Timesheet templates can be found on our website at: http://www.aaa1c.org/doing-business-with-us/purchase-of-service-pos-provider/
Participant/
Caregiver
Name
• Participant name
should be filled out
and spelled
correctly
• Employee actually
providing services
should be listed
• Week ending date
should be given
John Doe
Jane Doe
11/23/19
Date & Time
In/Time Out
• Dates should match
days of the week
• Time in and time out
should accurately
reflect the time the
caregiver arrived and
left
• Days with no services
provided should be
blank
• New month = new
timesheet should be
started
9:00AM 11:00AM 11/19/19
John Doe
Jane Doe
11/23/19
Unit
Breakdown
• Hours should be
converted into units
(1 hour = 4 units)
• Units should be
recorded in the
correct service code
box
• Units should be
carried down to the
“total units” box
9:00AM 11:00AM 11/19/19
John Doe
Jane Doe
8
8
11/23/19
Tasks
Completed
• Tasks should be
checked off for all
services completed
• Checked off tasks
should help show the
services the
participant received
each day and should
match services listed
on the authorization
9:00AM 11:00AM 11/19/19
John Doe
Jane Doe
8
8
11/23/19
Participant
Signature • Participant should only be signing
after services have been
provided on the same day they
were provided.
• Participants should not be signing
before the services are provided,
or a few days after.
• Caregivers should not submitting
pre-filled out/copied timesheets –
this is fraud.
• Caregiver, family members, etc.
should not be signing the
participant’s name for participant.
• Units should not be billed if
there is no participant signature.
• It should be confirmed that
participants are unable to sign
before noting on timesheets.
9:00AM 11:00AM 11/19/19
John Doe
Jane Doe
8
8 John Doe
11/23/19
Caregiver
Signature
• Caregivers should be
signing off and
therefore confirming the
services they provided
for the week.
• Caregiver signatures
should be dated.
• Units should not be
billed for timesheets
that are not signed and
dated by caregiver.
9:00AM 11:00AM 11/19/19
John Doe
Jane Doe
8
8 John Doe
Jane Doe
11/19/19
11/23/19
Timesheet Fraud
If TSA reviews timesheets and there is not evidence to support the units billed, TSA must recoup the funds.
If any timesheets appear to be fraudulently signed or filled out, TSA is required to report to the Office of Inspector General (OIG).
If the participant is in the hospital/nursing home/rehab/deceased and units are billed on these dates, TSA is required to recoup the funds and report to OIG.
Vendors must report to TSA if they believe any caregivers are submitting fraudulent timesheets as soon as they are aware of the problem.
Sending Secure Emails
All emails that contain any participant information, whether they are sent to TSA or anyone else at your agency, must be sent securely.
Instructions for sending secure emails to TSA: ..\POS 2018\New Vendors\Forms\Sending TSA a Secure Email.pdf
Caregivers should not be texting/emailing timesheets or any information about participants. All communication regarding participants should be made through HIPAA compliant portals.
Issues with Staffing
There is a staffing shortage throughout Michigan.
Many vendors have reported issues with hiring workers and consistently staffing cases.
TSA receives frequent complaints from participants about not receiving services.
If your agency is not able to staff a case, please let TSA staff know immediately so a new vendor can be found.
Participants cannot go weeks at a time without receiving services while vendors are searching for new staff.
Reporting Participant Status Changes
Vendors must report to TSA through vendor view any changes in participant status as soon as they are made aware of the change.
This includes admissions to the hospital, nursing home, or rehab facility.
Status changes that are not reported can have fraud implications.
Vendors must stress the importance of reporting hospitalizations to all caregivers, including those that are family or friends of the participant.
Caregivers should be made aware that not reporting hospitalizations and/or forging timesheets can jeopardize their ability to continue to care for their family member/friend.
If a vendor suspects that a caregiver is fraudulently signing a timesheet, this should be reported to the Office of Inspector General at the link https://oig.hhs.gov/fraud/report-fraud/index.asp, as well as TSA.
Communication
Vendors are required to keep the lines of communication open and provide ongoing feedback on participants.
This includes:
Clearing voicemail boxes so TSA staff can leave messages
Returning voicemails in a reasonable time frame
Checking vendor view messages every 24 hours
Having someone with vendor view access available to check vendor view messages every day during business hours
TSA is an expert in community supports and resources. If you identify anyone (participant, family member, caregiver, etc.) in need of resources, please call The Senior Alliance.
If your phone is not working temporarily, please let TSA know the best way to contact you for the time being.
TSA should be alerted when there is a change in address, phone number, email address etc.
Vendors must not contact participants after services have been stopped with your company.
Send a Vendor View Message for:
Missed visits by the caregiver for any hours worked less than the care plan
Visits/caregiver refused by the participant
Participant not home for visit
Not able to staff case
Falls/accidents/injuries
Change in participant mental/physical condition
Significant change to informal supports of the participant
Problems with the home/environment of the participant
Participant admitted to hospital, rehab, or nursing facility
Critical incident reporting (after phone call to SC has been made)
Changes in vendor view/vendor billing users
Changes in contact information, including phone numbers, addresses, EIN number, email addresses, etc.
Questions about authorizations
Anything containing Protected Health Information (PHI)
When in doubt, send a vendor view message.
Missed Visit Reporting
Missed visits should be reported through vendor
view AND vendor billing.
In vendor billing, all missed visits should be
documented using the following codes:
Missed Visit Codes
PC - PARTICIPANT CANCELLED VH - VENDOR HOLIDAY
PDH - PARTICIPANT DECREASED HOURS VIW - VENDOR INCLEMENT WEATHER
PH - PARTICIPANT HOSPITALIZED VNA - VENDOR/WORKER NO SHOW
PNA - PARTICIPANT NOT AVAILABLE VNA - VENDOR/WORKER NOT AVAILABLE
PNF - PARTICIPANT NURSING FACILITY VS - VENDOR/WORKER SICK
PRW - PARTICIPANT REFUSED WORKER VSP - VENDOR/WORKER SCHEDULING PROBLEMS
PS - PARTICIPANT SICK
Archiving Vendor View Notices/Messages
All Vendor View notices and messages should be archived once read within 24 hours of being posted.
By archiving a service authorization or assessment, you are accepting the person centered service plan, agreeing to the terms of the authorization, and agreeing to begin services on the authorized start date.
All service authorizations and assessments should be printed and placed in participant files once received.
Archived messages and notices can still be viewed in the “archived messages” tab.
If messages/notifications are not archived, TSA will assume that the message has not been read and Vendor is therefore out of compliance.
Vendor View should be checked at a minimum twice per day. A best practice is to keep Vendor View open at all times.
Notification through email is only sent through an automated system twice a day at 11:30AM and 3:30PM, so do not rely on the email system if you are in immediate need of an authorization.
Common Caregiver “Don’ts”
Caregivers/staff should be trained not to:
Discuss personal/financial problems with or in front of participants
Bring children, pets, or other family members to the homes of participants
Attempt to convince participants that they need more hours/services
Solicit participants to receive other services offered by the vendor, including services
not covered by the MI Choice, MI Health Link, or CM/CCS programs
Discuss participant information in front of another TSA participant, as this is a HIPAA
violation
Dress inappropriately/out of work uniform. Caregivers should be dressed
professionally and have picture ID/name badges on them
Use cellphones while at the home of participants
Sleep on the job
Use participant personal items
Smoke in participant homes
Smoke before/after/during the transportation of participants
Caregivers Working on Holidays
If you are authorized to provide services that fall
on a holiday, your agency must ensure that services
are provided that day.
Unless it is agreed upon with the participant that
services will be performed on a different day or
are all together canceled, Vendor must continue to
provide services on holidays.
Vendor Employee Exclusion List Review
Vendors must screen all employees with access to TSA client information through the following regulatory agencies before hire:
Michigan Department of Health and Human Services (MDHHS) Sanctioned Providers List
Office of Inspector General (OIG) Exclusions Database
System for Award Management (SAM) Debarment Search
TSA utilizes the service Provider Trust to conduct all exclusion checks for TSA employees.
Vendors must conduct exclusion reviews for employees on a monthly basis.
Documentation of conducting exclusion reviews must be printed and kept on file.
TSA cannot reimburse services performed by individuals who are excluded from receiving State or Federal Medicare/Medicaid funding.
Vendors must submit quarterly attestation forms to TSA certifying that they have conducted exclusion reviews for all employees.
Attestations are due on January 15, April 15, July 15, October 15 every year.
Criminal History Screenings
All vendors must conduct background checks for employees upon hire.
Background checks are required for any of the following individuals:
Any individual with ownership interest in the agency
Any individual who is providing services or has direct access to client information
Any person providing services to client that is reimbursed under Medicaid
Background checks must be conducted every 3 years at a minimum.
Vendors cannot hire caregivers with mandatory exclusions.
Caregivers with permissive exclusions can only be hired if:
Participant has chosen family/friend to be their caregiver (Personal Choice).
Participant signs a waiver stating that they are aware of the permissive exclusion.
Caregiver cannot serve any other participants.
Any excludable convictions discovered for current caregivers serving TSA
participants must be disclosed to TSA.
TSA cannot reimburse any services performed by caregivers who have
mandatory or permissive exclusions (excluding personal choice caregivers).
Criminal History Screenings
Employees with any of the following mandatory exclusions must not serve TSA participants:
Conviction of a criminal offense related to the delivery of an item or service under any federal or state health care program;
Conviction under federal or state law, relating to neglect or abuse of patients in connection with a delivery of a health care item or service;
Conviction of a felony criminal offense relating to fraud, theft, embezzlement, breach of fiduciary responsibility, or other financial misconduct, which occurred after August 21, 1996, under federal or state law, in connection with the delivery of health care items or services or with respect to any act or omission in a health care program (other than those specifically mentioned above), operated by or financed in whole or in part by any federal, state, or local government agency;
Conviction of a felony criminal offense, which occurred after August 21, 1996, under federal or state law, related to unlawful manufacture, distribution, prescription, or dispensing of a controlled substance.
MHL Permissive Exclusion Process
Vendors must obtain participant consent if they wish to receive service from a caregiver of their choice that has permissive exclusions.
The process is as follows:
1. TSA contacts vendor to let them know that a family caregiver would like to be credentialed through their agency.
2. Vendor runs background check and exclusion checks for the caregiver.
3. If the background check is clean, the vendor sends a vendor view message stating the date that the caregiver was hired.
4. If there are hits on the background check/exclusions, vendor faxes the results of the background check/exclusions to Attn: Melissa Gaynier at 734-727-2089.
5. MI Health Link Manager will review the background check/exclusions and make a determination if further action needs to be taken.
6. If the background check does not have a mandatory or permissive exclusion, vendors will receive a vendor view message stating that the caregiver can be hired.
7. If the background check has a mandatory exclusion, vendor will receive a vendor view message stating that the caregiver cannot be hired.
8. If the background check has a permissive exclusion, a vendor view message will be sent to the vendor stating that the vendor must meet with the participant and have them sign the attached form if they would like this caregiver to provide services.
9. Once the vendor has the participant sign the attached form, the caregiver is able to be hired and provide services to the participant. Vendor keeps a copy of the form with the participant file.
10. Vendor sends a copy of the signed permissive exclusion form to TSA via fax to Attn: Leanne and Kristin at 734-727-2089.
11. Vendor sends a vendor view message stating the date that the caregiver was hired.
CHAMPS/EVV
The State of Michigan currently has put a hold on accepting CHAMPS applications for atypical vendors. We have not received a new deadline for when vendors should be enrolled.
The deadline to implement an EVV system was January 1, 2020. However, the last notification we received from the state was that no action needs to be taken at this time.
The state of Michigan has applied for an exemption in order to extend the deadline to January 1, 2021.
TSA will continue to update when more information is received.
Updated Department of Labor Laws
Under the Fair Labor Standards Act, all home care providers are required to meet the minimum standards as outlined by the U.S. Department of Labor, effective January 1, 2015.
Please review the following document that outlines all requirements for home care providers: https://www.dol.gov/whd/homecare/homecare_guide.pdf
For additional information, please visit: https://www.dol.gov/whd/homecare/agencies.htm
Program Operational Guidelines &
Standards
Vendors should be familiar with MDHHS MI Choice and MI
Health Link Minimum Operating Guidelines.
TSA has updated the website with new MI Choice and MI Health
Link Operating Standards for FY 2020.
These standards show the minimum expectations TSA has for
each service performed.
The standards can be found on www.aaa1c.org at:
Business Partners POS Provider Service Standards
Fiscal/Programmatic Assessment
• Fiscal and Programmatic Assessments are performed to verify compliance with MDHHS, TSA, and AASA standards.
• TSA reserves the right to assess providers at any time during the fiscal year.
• Vendors must be prepared and have all documentation listed in tools pulled before the start of the
assessment.
• Timesheets must be:
Organized by the month (including the first and last week of the month) in alphabetical order by client name
Separated between MI Choice and MI Health Link
• All participant and employee files should be updated.
• Supervisory visit forms must show that an RN completed the visit, and a copy of the RN license must be available
during the assessment.
• Personnel files must include (but not limited to):
Background checks and exclusion checks
Licenses (RN, LPN, etc)
New hire documentation (I-9, W4, references, etc)
Training documentation
TB tests
Drivers Licenses, if applicable
Fiscal/Programmatic Assessment
If a large fiscal discrepancy is found at the first audit
conducted, TSA may elect to conduct a second audit on a
larger sample size.
Payroll records must demonstrate compliance with The Fair
Labor Standards Act and all other applicable Department of
Labor rules and regulations.
If a provider is non-compliant with TSA, MDHHS, or AASA
standards, the following actions may be taken:
Submit a Corrective Action Plan
Placed on Probationary Status
Funds deducted from future payment
Removed from the vendor pool
Authorizations/Billing
Units billed will only be approved if they are within the
weekly amount authorized.
“Times and days may vary” must exist within the weekly
amount authorized. Please verify that all applicable
authorizations state “times and days may vary” if
you are billing on dates outside the care plan.
Example – If a participant is out of town for one week,
they cannot make up their hours the following week.
The dates that services were provided on should always
match the dates billed.
Additional Billing Reminders
If you receive authorization for both Homemaking and
Personal Care services, do not go over either the
Homemaking or Personal Care weekly authorized units.
Make sure that units are not billed when authorizations
are stopped for the participant being in the hospital.
Vendors should bill by the timesheets, not by the care
plan.
Home care vendors who receive authorizations for
transportation mileage must have a corresponding log
documenting the mileage in order to bill.
Invoicing Information
Do not perform services until you have received WRITTEN authorization via Vendor View.
If you do not receive Vendor View authorization within 2 business days, immediately call
the Supports Coordinator or send a Vendor View message. Your invoice may be rejected.
Monthly billing is due by the 5th of each month.
Vendors cannot bill participant over and above what TSA reimburses vendors.
Billing should only be submitted once per month. Please do not send multiple batches per
billing cycle. If you receive late timesheets after your billing has been submitted, please
submit the following month.
Checks are released the Friday following the fourth Thursday of the month unless otherwise
noted. Vendors will be contacted via Vendor View with any changes or variation to this
schedule.
Please cash checks in a timely manner.
All billing forms and instructions can be found on the website at www.aaa1c.org
ACH Form
We encourage all vendors to use ACH forms.
Completed forms can be faxed to 734-727-2013.
When filling out the ACH form, please be sure that the routing number and account numbers are filled out correctly.
If an account number is entered wrong on the form, TSA is not responsible for missing payments.
ACH forms can be found on the website: http://www.aaa1c.org/doing-business-with-us/purchase-of-service-pos-provider/
Training
TSA is mandating that the following trainings be completed by staff on an annual basis :
Cultural Competency/Awareness of Personal Prejudices
ADA Compliance
Disability Awareness/Chronic Conditions
Person Centered Planning
Critical Incident/Abuse and Neglect Reporting
Fraud, Waste, and Abuse, Including 2 Medicare Compliance Trainings
HIPAA Compliance
These trainings will be presented annually at Vendor Meetings.
It is the responsibility of the vendor to make sure their staff is trained in these areas on an annual basis.
Any new employees hired throughout the year must be trained on these materials as well.
Please sign and submit the attestation form stating that trainings will be distributed to staff after this meeting.
Questions?
CULTURAL COMPETENCY &
AWARENESS OF PERSONAL
PREJUDICES
Awareness of personal prejudices (2.7.6.8.2)
What is Culture?
Culture is defined as a body of learned beliefs,
traditions, principles, and guides for behavior that
are shared among members of a particular group.
Culture competence is the capability of effectively
dealing with people from different cultures.
What is Culture Competence?
Cultural Considerations
Ethnicity
Race
Country of Origin
Gender/ Gender Identification
Age
Socio-Economic Status
Primary Language
English Proficiency
Literacy Level
Sexual Orientation
Employment
Geographic Location
Physical Ability / Limitations
Immigration Status
Criminal Justice Involvement
Political Affiliation
Spirituality / Religion
There are many factors that influence culture. These same factors can be
influenced by culture. The list below are just some of the things that can
influence or can be influenced by culture.
Cultural Competency Continuum
Developing cultural competency is a process. It takes
time, and happens along a continuum that involves
awareness, knowledge, and skills. Not everyone
starts in the same place on the continuum.
Cultural Competency Best Practices
Let individuals define goals, dreams, and aspirations based on their culture
Respect the differences between your culture and the individual’s culture.
Be conscious of personal behavior that could be considered insensitive by others.
As a sign of respect always ask the individual how they would like to be addressed.
Gesturing should be avoided; benign body or hand movements may have an adverse connotations in other cultures.
Cultural Competency Best Practices
Continued
When addressing issues that are very sensitive,
acknowledge the uncomfortable nature of the topic
and explain the importance of talking about it.
When preparing food for an individual always ask
if there are certain foods that they prefer or any
foods that they avoid due to cultural, religious, or
health reasons.
Always ask what language they prefer and
accommodate their request.
What is a personal prejudice?
An unjustified or incorrect attitude (usually negative)
towards an individual based solely on the individuals
membership of a social group.
This attitude could be based on socioeconomic status,
race, ethnicity or disability.
Awareness of personal prejudices
Based on the findings of a study completed by The Council on Quality and Leadership (CQL), there was a relationship between unconscious attitudes and defining disability as lacking independence, in relation to the norm or as impairment. Findings suggest people who define disability in relation to the norm have slightly more prejudice attitudes than people who define disability as a lacking of independence, or impairment. The longer someone works in the disability field, the more likely they are to understand disability as simply a general difference- a form of human variation.
LEGAL OBLIGATIONS TO
COMPLY WITH THE ADA
(2.7.6.8.3)
American Disability Act (ADA)
Compliance
The American Disabilities Act (ADA) prohibits
discrimination against persons with disabilities in the
area of employment, public accommodations and
telecommunications. ADA requires providers to
make reasonable access and accommodations for
all persons with disabilities.
Any Questions on ADA standards please review:
http://courts.mi.gov/Administration/SCAO/Resources/
Documents/Publications/Manuals/ADA-Handbook.pdf
ADA Standards
Building has handicap designated parking. Parking spaces are accessible with ramps and curb cutouts between the parking lot, office and at drop off locations.
Building has automatic entry option or alternative access method.
Building has elevator for public use (if building is multi-leveled). Elevator has enough room for the wheelchair and/or scooter to maneuver.
Restroom is equipped with large stall and safety bars or other reasonable accommodations.
ADA Standards
Waiting room (including furniture) can accommodate patients with physical and non-physical disabilities. The reception and waiting areas have enough room for a wheelchair and/or scooter to maneuver and turn around.
Doors to access building, office and patient rooms are at least 32 inches wide.
Signage and way finding is clear (i.e., color and symbol signage).
Larger print for written materials
Audio accommodations
DISABILITY AWARENESS &
CHRONIC CONDITIONS
Various Types of chronic conditions prevalent within the target population (2.7.6.8.1)
What is a disability?
According to the Americans with Disabilities Act (ADA), a person is considered to have a disability if he or she has a limitation to one or more major life activities.
Major life activities are primarily defined as:
Caring for oneself,
Preforming manual tasks,
Seeing and / or hearing,
Walking and / or standing and or lifting,
Speaking and / or breathing,
Learning
Communicating
Working
The Platinum Rule
What is the Platinum Rule?
Do unto others as they would want done to them
The Golden Rule, as great as it is, has limitations,
since all people and all situations are different.
When you follow the Platinum Rule, however, you
can be sure you're actually doing what the other
person wants done and assure yourself of a better
outcome.
Disability Awareness Best Practices
Talk directly to the person who has the disability, not
his or her companion, aid or interpreter.
Ask the person what their communication preference
is.
When talking to a person with disabilities, you
should first say “hello” then introduce yourself by
using your name and your position.
If possible, put yourself at eye-level with the person
you are speaking with. Listen attentively and be
patient.
Disability Awareness Best Practices
Continued
Ask a person about his or her disability and the
capabilities or limitations they may have.
Use People-First Language
Choose your words carefully
Don’t use the medical diagnosis as a label for the
person.
Emphasize capabilities, not restrictions.
Avoid the use of words that can create a negative
perception.
Disability Awareness Best Practices
Continued
Refrain from patronizing, or talking down, to a
person with disabilities. The level of challenge a
person with disabilities may encounter has no
bearing on their intelligence.
Before stepping in to help someone with a disability
always as, “Can I help you with that?” and be
respectful of their answer.
Cognitive Disabilities and Behavioral
Health Disorders Best Practices:
Generally considered “invisible” disabilities, and impact that the disability may have on an individual varies greatly from person to person.
If someone is not responding to you with accepted social norms (such as nodding in agreement), ask if he or she understands the topic. Speak with a normal tone, pace, and at a normal volume.
Don't feel the need to over explain. General comprehension is not typically a challenge to those with a cognitive disability or behavioral health disorder.
Mobility Devices and Aids Best
Practices
Always ask before helping
Do not crowd a person using a mobility aid.
Be conscious of that person’s reach limits.
Do not grab on to a person who is using a walker or
a cane.
Do not pet and or distract service animals.
Deafness and Hearing Loss Best
Practices
Speak directly to the person with the disability, not
to his or her interpreter.
Ask about preferred volume. Speak louder if you
are asked, do not assume that the person can or
cannot hear you.
If you are having difficulty understanding someone
with hearing loss or deafness, let them know.
Blindness or Low Vision Best
Practices
Introduce yourself using your name and/or position.
Speak directly to the person, not to a companion, guide, or other individual.
Speak using a natural conversational tone and speed.
Address the person by name when possible - this is especially important in crowded areas.
Immediately greet the person when he or she enters a room. This lets the person know that you are present.
Be prepared to offer assistance when asked.
Identify yourself before you make physical contact with a person who is blind.
Speech Disabilities Best Practices
Give the person your full attention.
Don't interrupt or finish the person's sentences.
If you have trouble understanding, don't nod. Just
ask them to repeat.
If you are not sure whether you have understood,
you can repeat for verification.
If, after trying, you still cannot understand the
person, ask him or her to write it down or to suggest
another way of facilitating communication.
Important Reminders
People with disabilities are individuals with families,
jobs, hobbies, likes and dislikes, and problems and
joys. While the disability is an integral part of who
they are, it alone does not define them. Don't make
them into heroes or victims. Treat them as individuals.
Do not make assumptions about what a person can
or cannot do based on his or her disability. All
people with disabilities are different and have a
wide variety of skills and personalities.
What is a chronic condition?
A disease or ailment that persists for a long time. A
disease that is lasting 3 months or more, by the
definition of the U.S. National Center for Health
Statistics.
Generally, these chronic conditions are not prevented or
cured by vaccines or medication.
88% of Americans over the age of 65 have at least
one chronic health condition, according to the U.S.
National Center for Health Statistics.
Examples of chronic conditions
Arthritis
Cardiovascular Disease
Cancer
Diabetes
Epilepsy and Seizures
Obesity
Oral health problems
PERSON CENTERED
PLANNING
Definition & Key Concepts
A set of approaches designed to assist someone to plan their life and supports. It is used most often as a life planning model to enable individuals with disabilities, or otherwise, requiring support to increase their personal self-determination and improve their own independence
It shifts power back to the participant
People are the expert of their own lives
Getting to know the person is the core of person centeredness.
We learn:
How the person wants to live
Builds upon their capabilities
Honors their preferences, choices, desires, and needs
Important To and Important For
As direct care providers we sometimes assume we
know what’s best for our participants.
Important To is an expressed desire for a person to
live life with an expressed choice (how they choose
to live).
Important For is something required for a person to
live.
Direct Support Professionals
You are important to the person centered process because you…
Know the person
Understand what is important to the person
Understand the person’s communication style/non verbal communication
Have a trusting relationship with the person
Support the person in different environments
Are the individual the person turns to for assistance and support
Your job is to encourage and support the individual while providing necessary daily care to keep them safe in their homes.
You are clearly an important part of each person’s life.
How to be Person Centered
In order to better assist participants and
understand their needs and wishes we must
• Listen to understand
• Ask Powerful and Open ended Questions
• Use Person First Language (names the person first
and the condition second, for example "people
with disabilities" rather than "disabled people“; to
avoid dehumanization)
• Attain a shared meaning
WAIVER ADVERSE
BENEFIT DETERMINATION
Definitions
Adverse benefit determination (ABD) - the reduction, suspension, or termination of a previously authorized service; or the failure of the waiver agency to act within the timeframes provided in §438.408(b)(1) and (2) regarding the standard resolution of grievances and appeals.
Appeal – A review by the waiver agency of an adverse benefit determination.
Grievance - an expression of dissatisfaction about any matter other than an adverse benefit determination.
If a participant has an appeal request or a grievance direct them to call The Senior Alliance and ask for any CCD Manager.
CRITICAL INCIDENT
REPORTING
What Are Critical Incidents?
A “Critical Incident” is any actual, alleged or suspected event or situation that creates a significant risk of substantial or serious harm to the physical or mental health, safety or well being of a program participant.
Reporting Critical Incidents:
It is a requirement by CMS (Centers for Medicare and Medicaid Services).
Federal Level
It is a requirement by MDHHS (Michigan Department of Health and Human Services).
State Level
Types of Incidents Reported
1. Exploitation
2. Illegal Activity in the
Home
3. Neglect
4. Physical Abuse
5. Provider No Show
6. Sexual Abuse
7. Suspicious death
8. Theft
9. Verbal Abuse
10. Worker
Drugs/Alcohol
11. Medication error
12. Suicide attempts
13. Use of restraints or
seclusion
14. Other
Mandated Reporters
A person who is employed, licensed, registered, or certified to provide health care, educational, social welfare, mental health, or other human services; an employee of an agency licensed to provide health care, educational, social welfare, mental health, or other human services; a law enforcement officer; or an employee of the office of the county medical examiner who suspects or has reasonable cause to believe that an adult has been abused, neglected, or exploited shall make immediately, by telephone or otherwise, an oral report to the county department of social services of the county in which the abuse, neglect, or exploitation is suspected of having or believed to have occurred. (Social
Welfare Act - Act 280 of 1939, 400.11)
Direct Care Providers
Direct Care Providers have a legal responsibility to report suspected abuse, mistreatment, or neglect and a relatively new obligation to report reasonable suspicions of a crime against a participant. Sometimes they can be held liable if they don’t and the abuse, mistreatment, or neglect is discovered.
As the direct care provider, you are not expected to investigate and draw the conclusion that abuse, neglect, or misappropriation has happened.
A Direct Care Provider’s only responsibility is to report any actual, alleged, or suspected incidents to the appropriate persons and explain their reason for concern.
Sometimes explanation for reason of concern is as simple as observing behaviors that are not normal or that seem worrisome.
Knowing this makes the responsibility less intimidating.
Once the report has been made, it is then the investigator’s responsibility to investigate and make the determination whether misconduct occurred and what punishment, if any, is imposed.
Critical Incidents that must be reported to
other entities:
Exploitation – Required to report to APS
Neglect – Required to report to APS
Verbal abuse – Required to report to APS
Physical abuse – Required to report to APS
Sexual abuse – Required to report to APS
Illegal activity in the home with potential to cause a serious or major negative event - local authorities/police
Suspicious or Unexpected Death – Death should be reported to law enforcement if it is a suspicious death possibly linked to abuse or neglect.
ALL critical incidents should be
reported to The Senior Alliance
It is the Senior Alliance’s responsibility to also investigate and report on ALL critical incidents to the MDHHS, APS, and Local Authorities as required.
Again, it is very important that The Senior Alliance’s Support Coordinator is notified of all critical incident types when they are actual, alleged, or suspected incidents.
If it is your policy for staff to report to their supervisor, it is important that either the direct care provider or the supervisor notifies TSA.
You can notify TSA’s Supports Coordinator
of Critical Incidents by phone only.
During your conversation with the Supports
Coordinator please inform us of:
1. Participants Name
2. Person(s) involved
3. Facts about the case
4. Information on what the direct care providers
observed, or suspects to be happening.
5. Explain reasons for cause of concern/reason for
worry.
How to file APS Reports
As always, call 911 if there is immediate danger to you or anyone else.
Reports can be anonymous
Police should be called if there is illegal activity
APS & CPS contact information: Centralized Intake for Abuse and Neglect (CPS/APS)
Phone: (855) 444-3911
Email: [email protected]
Fax: (616) 977-1154 or (616) 977-1158
Address: 5321 28th St. Ct. SE, Grand Rapids, MI 49546
Be prepared when calling. Review your notes and have the victim’s information available.
APS accepts phone referrals. Referrals must include:
Victim’s basic contact information
Description of suspected abuse, neglect or exploitation
As much other information as possible
Intake will accept or decline the referral
If accepted, worker goes to the home within 2 business days
APS tries to support the family/individual in the individual’s chosen living environment before recommending removal from the home
APS will file for guardianship or otherwise force removal from the home if no alternative
FRAUD, WASTE & ABUSE
Fraud
Fraud is knowingly and willfully executing, or attempting to execute, a scheme or artifice to defraud any health care benefit program, or to obtain, by means of false or fraudulent pretenses, representations, or promises, any of the money or property owned by, or under the custody or control of, any health care benefit program. The Health Care Fraud Statute makes it a criminal offense to knowingly and willfully execute a scheme to defraud a health care benefit program. This applies to the fraudulent completion and submission of timesheets/cards in order to collect payment for hours not worked, hours above what has been approved by the WA/SC and having the participant sign blank timesheets/cards. Health care fraud is punishable by imprisonment for up to 10 years. It is also subject to criminal fines of up to $250,000. (CMS)
Waste & Abuse
Waste includes overusing services, or other practices that, directly or indirectly, result in unnecessary costs to the Medicare Program. Waste is generally not considered to be caused by criminally negligent actions but rather by the misuse of resources. (CMS)
Abuse includes actions that may, directly or indirectly, result in unnecessary costs to the Medicare Program. Abuse involves payment for items or services when there is not legal entitlement to that payment and the provider has not knowingly and/or intentionally misrepresented facts to obtain payment. (CMS)
How To Report
For Medicare:
US Department of Health and Human Services (HHS)
Call 1-800-Medicare (1-800-663-4227)
TTY users call 1-877-486-2048
Online at https://oig.hhs.gov
For Medicaid:
Michigan Department of Community Health (MDHHS)
Phone (toll free): 1-855-MI-FRAUD (1-855-643-7283)
Online: www.michigan.gov/fraud
Write: Office of Inspector General (OIG), PO Box 30479 Lansing, MI 48909
AmeriHealth
Call: Anonymous Fraud Tip Hotline at 1-866-833-
9718.
Mail: Special Investigations Unit, 200 Stevens Drive,
Philadelphia, PA 19113
Aetna
https://www.aetnabetterhealth.com/michigan/frau
d-abuse
Submit a report on line at the link above or
You may prefer to contact their Special
Investigations Unit by calling 1-866-806-7020 or
our Aetna Medicaid-Medicare Compliance
Hotline number at 1-855-676-5820.
HAP
Call HAP's Compliance Hotline 24 hours a day at (877) 746-2501.
Report possible fraud in writing to HAP and include your contract number, date of service and other information that you think may be useful. Send your report to: HAP Compliance Department 2850 West Grand Boulevard Detroit, MI 48202
Michigan Complete Health
Compliance Help Line: 1-800-345-1642 or
Fraud Waste and Abuse Line: 866-685-8664
Molina
Telephone
Call the Toll-Free number of the Molina Healthcare Anti-Fraud Line: (866) 606-3889 TTY/TTD:711 Monday - Friday 8 AM - 5 PM local time
Online
Report an issue online through a confidential and secure site, visit: https://MolinaHealthcare.AlertLine.co m
Must Review and Distribute to Staff:
https://www.cms.gov/Outreach-and-
Education/Medicare-Learning-Network-
MLN/MLNProducts/Downloads/MedCandDGenCo
mpdownload.pdf
https://www.cms.gov/Outreach-and-
Education/Medicare-Learning-Network-
MLN/MLNProducts/Downloads/CombMedCandDF
WAdownload.pdf
THE HEALTH INSURANCE
PORTABILITY AND
ACCOUNTABILITY ACT
(HIPAA)
What is HIPAA?
A broad federal law passed in 1996 due to the rapid growth of health information systems and the need to safe guard individuals’ health information. That also addresses many health care privacy, security and electronic billing issues. It improves portability and continuity of health insurance coverage in the group and individual markets, and simplifies the administration of health insurance.
In some cases states may have different rules and restrictions. If the state laws are more stringent then those found in HIPPA we must follow the state’s regulation.
Privacy Standard
The Privacy Rule is a set of national standards for
the protection of certain health information.
These standards address the use and disclosure of
individuals’ Protected Health Information (PHI) by
organizations.
PHI – Individually identifiable health information.
PHI must have two components:
Medical Information includes
past, present, and future:
Health Status
Health Payment Information
Mental Care Received
Physical Health Care Received
Health Care Diagnosis
Dates of Services
Diagnosis Codes
Personally Identifiable
Information:
Name
Date of Birth
Address
Names of Relatives
Name of Employer
Telephone/ Fax Numbers
Email Address
Social Security Numbers
Covered Entities & Business Associates
The HIPAA Privacy Rule applies to all Covered Entities and their Business Associates.
Covered Entity – health care provider, health plan, or health care clearinghouse that electronically transmits and receives PHI.
Business Associates – an entity or person that preforms services or functions for a Covered Entity. The Privacy Rule allows a Covered Enmity to share PHI with its Business Associates. Prior to sharing, a Covered Entity must have a contract, call a Business Associate Agreement, that prohibits these Business Associates from using or disclosing PHI in any wat that would violate the Privacy Rule.
HIPAA Violations
Breach – An unauthorized acquisition, access, use or disclosure of PHI in a manner not permitted under HIPAA.
The Breach Notification Rule requires HIPPA Covered Entities and their Business Associates to provide notification following a breach of unsecure PHI. The Following must be notified: Individuals who are affected by a breach must be notified no
later than 60 days from the time of discovery.
Media – a breach that involves 500 or more individuals must be reported to the media no later than 60 days from discovery.
U.S Department of Health and Human Services – requires health care companies to submit a log of all breaches that are fewer than 500 individual once a year. Any breach that involves 500 or more individuals must be reported within 60 days from the time of discovery.
Use and Disclosure of PHI:
Use – To share, utilize, examine, or analyze PHI
within the Company.
Disclosure – to release, transfer, or share PHI to an
entity or person outside of the company.
A Covered Entity may not use or disclose an
individual's PHI except as permitted or required by
law.
Occasions where PHI can be disclosed
without individuals consent:
For Treatment of individuals
For Payment of a provider
For Health Care Operations
If required by Law or Law Enforcement
For Public Health Purposes
To Report Abuse
To Avert a Serious Threat
HIPAA Consent
Documents that individuals may use to give a
Covered Entity written consent to use or disclose
their PHI in ways not otherwise permitted by HIPAA.
Written Consent Must include:
The information to be used or disclosed
The name of the Covered Entity may disclose the
information
The purpose of the disclosure.
The expiration date
Individuals or personal representative’s signature.
HIPAA and you
The minimum necessary rule restricts the use and
disclosure of PHI to the least amount necessary to
preform a specific task.
Look at PHI only if your task requires it.
Use only the minimum amount of PHI needed to
complete your task.
Talk to others about PHI only if it is necessary to
preform your task.
Give PHI to others only when it is necessary for them to
preform their tasks.
HIPAA Compliance
It is everyone’s responsibility to:
Remain vigilant in preventing unauthorized access or
actions.
Watch for unauthorized use or disclosure of PHI
Safeguard PHI
Computer Security Guidelines
Never allow anyone to use your computer
Never share your username/ password with anyone
Never write down your password and leave it
unsecured or in a public space
Always lock your computer before you step away
from your work space
Ensure your laptop is in the docking station when
you leave for the day
Always use a “strong password” that contains and
alphanumeric and special charters.
Email Security Guidelines
You may not email or forward PHI to anyone unless
it is needed to preform a specific task
You may not email proprietary/ confidential
information to personal email accounts.
If sending PHI always use secure email, if
communicating with TSA about any participant
vendor view should be used.
Double – check your recipients before you send out
or reply to any email regarding PHI.
Fax Security Guidelines
If sending PHI by fax, you must use a standard
cover sheet, which includes a confidentiality
statement.
Double check the accuracy of the destination
number before sending the fax.
You must check transmittal records for each fax that
contains PHI immediately after the transmission.
Public Areas Security Guidelines:
You should always be aware of your surroundings regarding PHI .
Refrain from having conversations concerning members’ claims or other PHI when in an unsecured area.
If necessary, when discussing PHI in an unsecured area, refrain from using specific information that may identify a specific member/ participant/ or case.
When handling PHI in public areas, make sure it is away from prying eyes and secure all documents before departing.
Workspace Security Guidelines:
Documents that contain PHI should never be left
around your work space at any given time.
Paper documents containing PHI should be shredded
when no longer needed.
PHI and sensitive documents should always be
stored within locked drawers, cabinets, containers,
or rooms.
Reporting Compliance Concerns
Concerns can be reported through your agency process
or may be reported directly to TSA. To report to TSA:
Call 734-722-2830, ext. 2001
Email [email protected]
To report anonymously, mail concerns to:
The Senior Alliance
Attn: Compliance Officer
5454 Venoy
Wayne, MI 48184
Abbreviations
MHL – MI Health Link
MDHHS – Michigan Department of Health and Human Services
CIM – Center for Information Management Inc.
CHAMPS - Community Health Automated Medicaid Processing System
EVV – Electronic Visit Verification System
AASA – Aging and Adult Services Agency
OIG – Office of Inspector General
SAM – System for Award Management
CCD – Community Care Department
POS – Purchase of Service
NEMT – Non-Emergency Medical Transportation
SC – Supports Coordinator
ARE THERE ANY QUESTIONS?
Thank you for attending
The Senior Alliance
Annual Vendor Meeting and Training
References
https://courses.mihealth.org/MIHealthLink/home.ht
ml
https://www.cms.gov/Outreach-and-
Education/Medicare-Learning-Network-
MLN/MLNProducts/Downloads/HIPAAPrivacyandSe
curity.pdf
Acknowledgement of Attending
The Senior Alliance Annual Provider Meeting and Training
November 5, 2019
I acknowledge that I have attended The Senior Alliance Annual Provider Meeting and Training as a
representative of my agency. I understand that the organization I represent must follow these
Guidelines and Operational Standards to ensure payment for services provided and continuation of
agreement with The Senior Alliance. I attest that the training topics covered on this date will be covered
annually with all staff, and evidence of these trainings will be kept in employee files.
Agency name: _____________________________________________________
Agency representative’s printed name: ________________________________________________
Agency representative’s signature: ___________________________________________________
Date: __________________________
